26 Idaho opinions name it 2 courts 1947–2026 2 in the last five years
The cases below were cited by Idaho courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Matthews v. Stategreen2 sentences2010In Stone, we set forth the policy and standards of the corroboration requirement as follows: “This statutory corroboration requirement is intended to protect against the danger that an accomplice may wholly fabricate testimony, incriminating an innocent defendant in order to win more favorable treatment for the accomplice.” Matthews v. State, 136 Idaho 46, 49 , 28 P.3d 387, 390 (Ct. App. 2001). 2010In Stone, we set forth the policy and standards of the corroboration requirement as follows: “This statutory corroboration requirement is intended to protect against the danger that an accomplice may wholly fabricate testimony, incriminating an innocent defendant in order to win more favorable treatment for the accomplice.” Matthews v. State, 136 Idaho 46, 49 , 28 P.3d 387, 390 (Ct. App. 2001). | 3 | 3 |
Opper v. United Statesgreen2 sentences2013See Opper, 348 U.S. at 92-93 , 75 S.Ct. at 164—65, 99 L.Ed. at 108-09 , (wherein the Supreme Court reviewed the various ways in which federal courts had applied the corroboration requirement); 29A Am.Jur.2d Evidence § 777 (2008) (discussing varying applications of the rule). 2013See Opper, 348 U.S. at 92-93 , 75 S.Ct. at 164—65, 99 L.Ed. at 108-09 , (wherein the Supreme Court reviewed the various ways in which federal courts had applied the corroboration requirement); 29A Am.Jur.2d Evidence § 777 (2008) (discussing varying applications of the rule). | 2 | 2 |
State v. Elsengreen2 sentences1991The corroboration requirement in sex crime cases was well summarized by Justice Hyatt, writing for the Court in State v. Elsen, 68 Idaho 50, 54 , 187 P.2d 976, 978 (1947): If the character or reputation of the prosecutrix for truth and chastity is unimpeached, and her testimony is not contradictory nor inconsistent with the admitted facts of the case, and is not inherently improbable nor incredible, there can be either direct evidence corroborating her testimony, or evidence of surrounding circumstances clearly corroborating her statements. 1991The corroboration requirement in sex crime cases was well summarized by Justice Hyatt, writing for the Court in State v. Elsen, 68 Idaho 50, 54 , 187 P.2d 976, 978 (1947): If the character or reputation of the prosecutrix for truth and chastity is unimpeached, and her testimony is not contradictory nor inconsistent with the admitted facts of the case, and is not inherently improbable nor incredible, there can be either direct evidence corroborating her testimony, or evidence of surrounding circumstances clearly corroborating her statements. | 2 | 2 |
State v. Byersgreen2 sentences2009In Byers , we rejected the corroboration requirement in sex crime cases. 102 Idaho at 165 , 627 P.2d at 793 . 2009In Byers , we rejected the corroboration requirement in sex crime cases. 102 Idaho at 165 , 627 P.2d at 793 . | 1 | 3 |
State v. Campbellgreen2 sentences2008As this Court explained in State v. Campbell, 114 Idaho 367 , 757 P.2d 230 (Ct.App.1988), the corroboration requirement is designed to prevent a conviction that is based on false testimony actuated by an accomplice’s self-interest: The purpose of the corroboration requirement is to offset the danger that an accomplice may wholly fabricate testimony inculpating an innocent person in order to win more lenient treatment for the alleged accomplice. 2008As this Court explained in State v. Campbell, 114 Idaho 367 , 757 P.2d 230 (Ct.App.1988), the corroboration requirement is designed to prevent a conviction that is based on false testimony actuated by an accomplice’s self-interest: The purpose of the corroboration requirement is to offset the danger that an accomplice may wholly fabricate testimony inculpating an innocent person in order to win more lenient treatment for the alleged accomplice. | 1 | 3 |
State v. Piercegreen2 sentences1989State v. Pierce, 107 Idaho 96 , 685 P.2d 837 (Ct.App.1984). 1989State v. Pierce, 107 Idaho 96 , 685 P.2d 837 (Ct.App.1984). | 1 | 2 |
State v. Masongreen2 sentences1975Facts and circumstances showing that the parties had been together under conditions that made it possible for the commission of the offense, without showing other facts and circumstances that tend to support the testimony of the prosecutrix, is not the corroboration required by this rule." State v. Mason, 41 Idaho 506, 510 , 239 P. 733, 734 (1925). 1975Facts and circumstances showing that the parties had been together under conditions that made it possible for the commission of the offense, without showing other facts and circumstances that tend to support the testimony of the prosecutrix, is not the corroboration required by this rule." State v. Mason, 41 Idaho 506, 510 , 239 P. 733, 734 (1925). | 1 | 2 |
State v. Mark Lankfordgreen2 sentences2023Without his testimony at that trial, we concluded there was “a ‘reasonable likelihood’ that Thomas’ false testimony about his motive for testifying ‘could have affected the judgment of the jury.’ ” Mark Lankford III, 162 Idaho at 507 , 399 P.3d at 834 (emphasis in original). 2023Without his testimony at that trial, we concluded there was “a ‘reasonable likelihood’ that Thomas’ false testimony about his motive for testifying ‘could have affected the judgment of the jury.’ ” Mark Lankford III, 162 Idaho at 507 , 399 P.3d at 834 (emphasis in original). | 1 | 1 |
State v. Meistergreen2 sentences2020In reaching this conclusion, the district court relied on the Idaho Supreme Court’s decision in State v. Meister, 148 Idaho 236 , 220 P.3d 1055 (2009), which adopted a seven-factor test for analyzing the corroboration requirement in Rule 804(b)(3)(B). 2 Those factors are: (1) whether the declarant is unavailable; (2) whether the statement is against the declarant’s interest;[3] (3) whether corroborating circumstances exist which clearly indicate the trustworthiness of the exculpatory statement, taking into account contradictory evidence, the relationship between the declarant and the listener, 2020In reaching this conclusion, the district court relied on the Idaho Supreme Court’s decision in State v. Meister, 148 Idaho 236 , 220 P.3d 1055 (2009), which adopted a seven-factor test for analyzing the corroboration requirement in Rule 804(b)(3)(B). 2 Those factors are: (1) whether the declarant is unavailable; (2) whether the statement is against the declarant’s interest;[3] (3) whether corroborating circumstances exist which clearly indicate the trustworthiness of the exculpatory statement, taking into account contradictory evidence, the relationship between the declarant and the listener, | 1 | 1 |
State v. Mitchellgreen2 sentences2010The corroborating evidence required by I.C. § 19-2117 need not “be sufficient to sustain a conviction on its own, nor must it corroborate every detail of the accomplice‟s testimony.” State v. Mitchell, 146 Idaho 378, 382 , 195 P.3d 737, 741 (Ct. App. 2008). 2010The corroborating evidence required by I.C. § 19-2117 need not “be sufficient to sustain a conviction on its own, nor must it corroborate every detail of the accomplice‟s testimony.” State v. Mitchell, 146 Idaho 378, 382 , 195 P.3d 737, 741 (Ct. App. 2008). | 1 | 1 |
State v. LaGrandgreen2 sentences2009The court ultimately held that “a judge’s inquiry, made to assure himself [or herself] that the corroboration requirement of Rule 804(b)(3) has been satisfied, should be limited to asking whether evidence in the record corroborating and contradicting the declarant’s statement would permit a reasonable person to believe that the statement could be true.” Id. at 28, 734 P.2d at 570 (emphasis added). 2009This will protect the province of the jury as the fact-finder and prevent the judge from “be[ing] able to bootstrap himself [or herself] into the jury box via evidentiary rules.” Id. | 1 | 1 |
State v. Mooregreen2 sentences2009Nevertheless, in Moore , despite our abandonment of the corroboration requirement in prosecutions for sexual offenses, this Court held that although corroborating evidence "is no longer mandatorily required in all sex crime cases, corroborating evidence may still be relevant, particularly in sex crime cases involving minor victims." 120 Idaho at 746 , 819 P.2d at 1146 (footnote omitted). 2009Nevertheless, in Moore , despite our abandonment of the corroboration requirement in prosecutions for sexual offenses, this Court held that although corroborating evidence "is no longer mandatorily required in all sex crime cases, corroborating evidence may still be relevant, particularly in sex crime cases involving minor victims." 120 Idaho at 746 , 819 P.2d at 1146 (footnote omitted). | 1 | 1 |
State v. Pecorgreen2 sentences2008State v. Pecor, 132 Idaho 359, 367 , 972 P.2d 737, 745 (Ct.App.1998); State v. Campbell, 114 Idaho 367, 369 , 757 P.2d 230, 232 (Ct.App.1988). 2008State v. Pecor, 132 Idaho 359, 367 , 972 P.2d 737, 745 (Ct.App.1998); State v. Campbell, 114 Idaho 367, 369 , 757 P.2d 230, 232 (Ct.App.1988). | 1 | 1 |
United States v. Luis Oscar Sarmiento-Perezgreen2 sentences1984See U.S. v. SarmientoPerez, 633 F.2d 1092 ; U.S. v. Oliver, 626 F.2d 254 (2nd Cir.1980); U.S. v. Alzarez, 584 F.2d 694 ; State v. Parris, 98 Wash.2d 140 , 654 P.2d 77 (1982). 1984See U.S. v. Sarmiento-Perez, 633 F.2d 1092 ; U.S. v. Oliver, 626 F.2d 254 (2nd Cir.1980); U.S. v. Alzarez, 584 F.2d 694 ; State v. Parris, 98 Wash.2d 140 , 654 P.2d 77 (1982). | 1 | 1 |
State v. Bassettgreen2 sentences1984See also State v. Bassett, 86 Idaho 277 , 385 P.2d 246 (1963); State v. Larsen, 91 Idaho 42 , 415 P.2d 685 (1966). *842 The purpose of the corroboration rule, embodied in I.C. § 19-2117, is to offset the danger that an accomplice may wholly fabricate testimony, inculpating an innocent person, in order to purchase immunity from prosecution, or lenient treatment, for his own complicity in the crime. 1984See also State v. Bassett, 86 Idaho 277 , 385 P.2d 246 (1963); State v. Larsen, 91 Idaho 42 , 415 P.2d 685 (1966). *842 The purpose of the corroboration rule, embodied in I.C. § 19-2117, is to offset the danger that an accomplice may wholly fabricate testimony, inculpating an innocent person, in order to purchase immunity from prosecution, or lenient treatment, for his own complicity in the crime. | 1 | 1 |
People v. Beilfussgreen2 sentences1984People v. Beilfuss, 59 Cal.App.2d 83 , 138 P.2d 332, 337 (1943). 1984People v. Beilfuss, 59 Cal.App.2d 83 , 138 P.2d 332, 337 (1943). | 1 | 1 |
State v. Adairgreen2 sentences1981See, e. g., State v. Adair, 99 Idaho 703 , 705 n.2, 587 P.2d 1238 , 1240 n.2 (1978). 1981See, e. g., State v. Adair, 99 Idaho 703 , 705 n.2, 587 P.2d 1238 , 1240 n.2 (1978). | 1 | 1 |
State v. Cabralgreen2 sentences1981"The corroboration requirement, in effect, arbitrarily singles out victims of sex offenses as a class whose credibility is immediately suspect." 410 A.2d at 441 (footnotes omitted). 1981“The corroboration requirement, in effect, arbitrarily singles out victims of sex offenses as a class whose credibility is immediately suspect.” 410 A.2d at 441 (footnotes omitted). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
United States v. Herman Sheppardgreen2 sentences1981The court in United States v. Sheppard, supra, elaborated further on how the corroboration rule both stands in the way of legitimate convictions and is unnecessary to protect an innocent defendant: “The corroboration requirement poses a potentially severe obstacle to legitimate convictions for sex offenses. 1981The court in United States v. Sheppard, supra, elaborated further on how the corroboration rule both stands in the way of legitimate convictions and is unnecessary to protect an innocent defendant: “The corroboration requirement poses a potentially severe obstacle to legitimate convictions for sex offenses. | 1 | 2 |
| Case | Cited | Years |
|---|---|---|
State v. Larsen
green
2 sentences2009This Court accepted review on the following issues: (1) whether this Court’s decision in State v. Larsen, 91 Idaho 42 , 415 P.2d 685 (1966) or I.R.E. 403 is the controlling authority for the. admissibility of alternate perpetrator evidence, (2) whether I.R.E. 804(b)(3) contains a corroboration requirement for the admission of confessions of an alternate perpetrator, and (3) whether the district court violated Meister’s right to due process, right of appeal, and Fifth Amendment rights by threatening a harsher sentence if Meister refused to admit guilt. 2009This Court accepted review on the following issues: (1) whether this Court’s decision in State v. Larsen, 91 Idaho 42 , 415 P.2d 685 (1966) or I.R.E. 403 is the controlling authority for the. admissibility of alternate perpetrator evidence, (2) whether I.R.E. 804(b)(3) contains a corroboration requirement for the admission of confessions of an alternate perpetrator, and (3) whether the district court violated Meister’s right to due process, right of appeal, and Fifth Amendment rights by threatening a harsher sentence if Meister refused to admit guilt. | 2 | 1984–2009 |
Arnold v. United States
green
2 sentences1981Cir.1977) (the court abolished the requirement of corroboration and affirmed the convictions without discussing the ex post facto problem); Arnold v. United States, 358 A.2d 335 (D.C.App. 1976) (the court abolished the corroboration requirement, saying that although the trial court erred in refusing to give the corroboration instruction, such error was harmless). 1981But see United States v. Sheppard, 569 F.2d 114 (D.C.Cir.1977) (the court abolished the requirement of corroboration and affirmed the convictions without discussing the ex post facto problem); Arnold v. United States, 358 A.2d 335 (D.C.App.1976) (the court abolished the corroboration requirement, saying that although the trial court erred in refusing to give the corroboration instruction, such error was harmless). | 2 | 1978–1981 |
United States v. Aguero-Miranda
green
1 sentence2026A defendant may not be convicted on the testimony of an accomplice unless the testimony is “corroborated by other evidence, which in itself, and without the aid of the testimony of the accomplice, tends to connect the defendant with the commission of the offense.” I.C. § 19-2117. 3 United States v. Sutton, 794 F.2d 1415 (9th Cir. 1986) (holding that collective knowledge doctrine applied where United States Customs officials contacted local state police to perform an investigatory stop); United States v. Ibarra-Sanchez, 199 F.3d 753 (5th Cir. 1999) (same but Drug Enforcement Administration (DEA | 1 | 2026–2026 |
United States v. William John Sutton, United States of America v. Freddie Goldbaum Ortiz, United States of America v. Valentine Frank Proitte
green
1 sentence2026A defendant may not be convicted on the testimony of an accomplice unless the testimony is “corroborated by other evidence, which in itself, and without the aid of the testimony of the accomplice, tends to connect the defendant with the commission of the offense.” I.C. § 19-2117. 3 United States v. Sutton, 794 F.2d 1415 (9th Cir. 1986) (holding that collective knowledge doctrine applied where United States Customs officials contacted local state police to perform an investigatory stop); United States v. Ibarra-Sanchez, 199 F.3d 753 (5th Cir. 1999) (same but Drug Enforcement Administration (DEA | 1 | 2026–2026 |
United States v. Marco Burton
green
1 sentence2026A defendant may not be convicted on the testimony of an accomplice unless the testimony is “corroborated by other evidence, which in itself, and without the aid of the testimony of the accomplice, tends to connect the defendant with the commission of the offense.” I.C. § 19-2117. 3 United States v. Sutton, 794 F.2d 1415 (9th Cir. 1986) (holding that collective knowledge doctrine applied where United States Customs officials contacted local state police to perform an investigatory stop); United States v. Ibarra-Sanchez, 199 F.3d 753 (5th Cir. 1999) (same but Drug Enforcement Administration (DEA | 1 | 2026–2026 |
State v. Scroggins
green
2 sentences2018In State v. Scroggins , 110 Idaho 380 , 386, 716 P.2d 1152 , 1158 (1985), the defendant was convicted based largely on testimony from an accomplice. 2018In State v. Scroggins , 110 Idaho 380 , 386, 716 P.2d 1152 , 1158 (1985), the defendant was convicted based largely on testimony from an accomplice. | 1 | 2018–2018 |
State v. Parris
green
2 sentences1984See U.S. v. SarmientoPerez, 633 F.2d 1092 ; U.S. v. Oliver, 626 F.2d 254 (2nd Cir.1980); U.S. v. Alzarez, 584 F.2d 694 ; State v. Parris, 98 Wash.2d 140 , 654 P.2d 77 (1982). 1984See U.S. v. SarmientoPerez, 633 F.2d 1092 ; U.S. v. Oliver, 626 F.2d 254 (2nd Cir.1980); U.S. v. Alzarez, 584 F.2d 694 ; State v. Parris, 98 Wash.2d 140 , 654 P.2d 77 (1982). | 1 | 1984–1984 |
United States v. Jessie Oliver and Gregory Cooper
green
2 sentences1984See U.S. v. SarmientoPerez, 633 F.2d 1092 ; U.S. v. Oliver, 626 F.2d 254 (2nd Cir.1980); U.S. v. Alzarez, 584 F.2d 694 ; State v. Parris, 98 Wash.2d 140 , 654 P.2d 77 (1982). 1984See U.S. v. Sarmiento-Perez, 633 F.2d 1092 ; U.S. v. Oliver, 626 F.2d 254 (2nd Cir.1980); U.S. v. Alzarez, 584 F.2d 694 ; State v. Parris, 98 Wash.2d 140 , 654 P.2d 77 (1982). | 1 | 1984–1984 |
State v. Boetger
green
2 sentences1984State v. Boetger, 96 Idaho 535 , 531 P.2d 1180 (1975); see also 7 J. 1984State v. Boetger, 96 Idaho 535 , 531 P.2d 1180 (1975); see also 7 J. | 1 | 1984–1984 |
United States v. Gilberto Pablo Alvarez
green
2 sentences1984See U.S. v. SarmientoPerez, 633 F.2d 1092 ; U.S. v. Oliver, 626 F.2d 254 (2nd Cir.1980); U.S. v. Alzarez, 584 F.2d 694 ; State v. Parris, 98 Wash.2d 140 , 654 P.2d 77 (1982). 1984See U.S. v. Sarmiento-Perez, 633 F.2d 1092 ; U.S. v. Oliver, 626 F.2d 254 (2nd Cir.1980); U.S. v. Alzarez, 584 F.2d 694 ; State v. Parris, 98 Wash.2d 140 , 654 P.2d 77 (1982). | 1 | 1984–1984 |
State v. Rassmussen
green
2 sentences1981Therein the Court observed, citing State v. Anderson, 6 Idaho 706 , 59 P. 180 (1899), that the corroboration rule in rape cases was court-made law, while Wigmore was quoted for the proposition that corroboration was not required at common law. 92 Idaho at 732-33 , 449 P.2d at 838-39 . 1981Therein the Court observed, citing State v. Anderson, 6 Idaho 706 , 59 P. 180 (1899), that the corroboration rule in rape cases was court-made law, while Wigmore was quoted for the proposition that corroboration was not required at common law. 92 Idaho at 732-33 , 449 P.2d at 838-39 . | 1 | 1981–1981 |
| State v. Anderson green | 1 | 1981–1981 |
| People v. Rincon-Pineda green | 1 | 1978–1978 |
| State v. Ross green | 1 | 1975–1975 |
| State v. Short green | 1 | 1975–1975 |
| State v. Jones green | 1 | 1975–1975 |
| State v. Tope green | 1 | 1975–1975 |
| State v. Madrid green | 1 | 1975–1975 |
| State v. Emmons green | 1 | 1972–1972 |
| State v. Carr green | 1 | 1972–1972 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.